OSHA enforces NFPA70E?

[realolman]

Re: OSHA enforces NFPA70E?

Hey wirenut I'm not offended. And I hope I'm not offensive.

I truly don't understand why experienced electricians would think it is necessary to wear rubber gloves and who knows what to take a simple volt reading or PLC output or something of that nature, because it is in a power cabinet. PPE to check after lockout? Come on... how can that not be absolute overboard?

Seriously, what do you suppose the odds are of being injured in that task? I think they are about nil.

 

[augie47]

Re: OSHA enforces NFPA70E?

I truly don't understand why experienced electricians would think it is necessary to wear rubber gloves and who knows what to take a simple volt reading

real,
I'm not saying I do it (and I;m not admitting I don't), but, to some degree, well pay for someone else's mistake.
I was called to help investigate a serious electrical accident. A relative well qualified electrician had taken a rather inexpensive VOA meter, one that fit easily in his hand (bare hand), went to check voltage on a sizable panelboard with the meter set on ohms. Simple task--making sure the panelboard was not energized...
many operations later, he regained the use of that hand and only a few burns can still be seen.
I, for one, would not argue that the PPE regulations area bit overboard, but we must not forget the simplest of tasks in our profession can still be dangerous, and some degree of "protection" is always a good idea.

 

[realolman]

Re: OSHA enforces NFPA70E?

Thank you, Augie.

No one wants to see anyone hurt, least of all themselves, but this stuff has gone overboard and misses the point.

You cited a prime example... Is anyone regulating the use of $5.00 junk meters? Are there any regs specifying what exactly constitutes "qualified". ...Or is it just dress everybody up in moon suits... The "training films" I saw showed guys getting set on fire at 5kV switch gear, inside a chain link fence. They talked about a guy geting hit by a wire rope that fell across some 28kv something. That's a lot easier for safety directors to understand than electricity. Buy the moon suit.

 

[wirenut1980]

Re: OSHA enforces NFPA70E?

The "training films" I saw showed guys getting set on fire at 5kV switch gear

I think I saw that one too

 

[zog]

Re: OSHA enforces NFPA70E?

"Is anyone regulating the use of $5.00 junk meters?"

Thats what the CAT ratings are for.

"Are there any regs specifying what exactly constitutes "qualified"?"

NFPA 70E and OSHA

. ...Or is it just dress everybody up in moon suits.

Maybe, it depends on the results of your flash hazard analysis.

 

[goodcode]

Re: OSHA enforces NFPA70E?

I don,t get an oppurtunity to visit this site very often and rarely leave replies unless I feel I have something of value to offer other electrical workers.
This topic is perhaps one of the most important to be discussed in this venue.
I have had the unfortunate responsibility to go to the burn centers and visit members burned from the extreme radiant heat generated in an arc flash. The only thing harder than explaining to a family member how those extreme temperatures can be generated is telling them that their loved one knew the risking he was taking as well as the possible consequences.
As a prerequisite to asking a question about the NEC, members of this website should be required to visit the safety postings.
Please keep discussing these issues. I have a few things to offer which may aid in your discussion.
When discussing OSHA and safe work practices, one must first determine wheteher the task at hand falls under the 1926 construction or 1910 general industry standards. The letters of interpretation on this topic are extremely useful.
In essence if it is an improvement (anything other than replcing like kind for repair) it is construction.
In subart K of the 1926 construction standard 1926.416 literally prohibits contact, meaning that voltage testing would be prohibited. OSHA realized very early after the act was signed in 1970 that this was a problem. We need to troubleshoot and do startup. We need to do it safely. OSHA formally contacted NFPA in 1976 to request that NFPA build a "prescriptive" standard for electrical safe work practices. NFPA-70E is essentially an infant when it comes to codes and standards.
In subpart S of the 1910 general industry standard 1910.333 looks a whole lot like the basic NFPA-70E approach for good reason. It came from NFPA-70E and includes the "infeasability" and "greater hazard" thresholds outlined in Article 130 of the 70E standard.
OSHA cannot use the general duty clause outlined in section 5(a)(1) of the act if there is an applicable vertical standard.
An OSHA investigation of a serious arc flash incident in construction always contains citations in 1926.95 for PPE and 1926.416 for exposure.
An OSHA investigation of a serious arc flash incident in general industry always contains citations in 1910.333.
OSHA cannot cite NFPA-70E unless it is done in the alternative as outlined in the Field Inspection Reference Manual or FIRM. This is done in many cases to accomplish two goals (1) strengthen the citation and (2) illustrate an industry based consensus standard for the employer to use in the future.
In essence all employers must protect their employees. OSHA says that you SHALL but does not show the employer HOW.
NFPA-70E will become the HOW.
It is extremely easy today for me when working as an expert wittness to prove that an employer: (1) had knowledge of the hazards and (2) had knowldege of an industry standard which provides prescriptive steps to protect employees, such as NFPA-70E . Once those two points are illustrated its over. Settlement. They just dont go to court.
As illustrated in your discussion the typical electrical worker with 15 or more years of experience thinks and may publicly states that the PPE is overkill and the guy that got killed screwed up.
It is only after these electrical workers spend a week in the burn center and have their wounds scrubbed daily for weeks (the morphine doesnt help) that they realize that in essence they have been playing a dangerous game of russian roulette for years and their luck has run out.
Our industry will change.
Many will be relctant and fight change.
They will lose, change will occur, driven primarily by insurance companies, owners and 3rd party civil suits.
This has been a long winded reply and since Charlie the utility guy owes me big after his loss in a recent golf game, see him for a cold beer on me.
W. Edwards Demming, a famous statitician and electrical engineer is quoted as follows:
"Change is not necessary because survival is not mandatory."
Words to dwell on over a beer tonight.
I have chosen to change. Our industry will move in that direction.
For safety sake get in the front of that line.

 

[ralpha494]

Re: OSHA enforces NFPA70E?

Goodcode, you get a standing ovation from me. Thanx. Well said. I'm sure your message will be referred to for a long time from other forums as well as this one. I'm gonna print it and use it in the 70E class I train others in. Thanx again.

 

[realolman]

Re: OSHA enforces NFPA70E?

Goodcode, perhaps if I made my living in the regulations industry, I might agree, but I deal with industrial problems on the plant floor and I am quite offended by your post. I find it ironic that you would quote Deming to justify stifling regulation. What you discuss in your post is not safety, but regulation.

I am one of the people who is "actually in the arena". I am not in the air conditioning; I resent the implication ( or perhaps it was a statement ) that I have been nothing but lucky in 32 years of safe electrical work. Your reply reflects what many people ignorantly think... that the guy on the plant floor couldn't possibly have any intelligence, skills, or abilities. If he's done something good, it must be luck.

I am telling you that I have worked on various electrical systems for 32 years and have not once caused an arc flash incident. The proof is in the pudding. Instead of receiving even perfunctory respect for such an accomplishment, I see from you that I and the other "typical electrical workers with more than 15 years of experience" have been playing Russian roulette. I am an individual, and I can assure you that I have been doing no such thing as stupid as playing Russian Roulette.

The melodramatic description of the burn unit and the morphine is exactly the kind of emotional drivel that is a disservice to this subject and discussion, but is exactly what is being used to sell fuses, training courses, stickers, surveys... and yes moon suits. I am not advocating getting burned. I am advocating being skilled enough to avoid it, and being left alone enough to apply those skills. If you don't feel comfortable without a moon suit, please wear one.

I work on hundreds of thousands of dollars of equipment on a daily basis. It is already way too hot out there. I don't know how I get this stuff going without help from the regulators, considering I need help getting dressed.

I have no doubt that I and people like me will lose this one. I do not believe it is safety driven at all, but insurance driven. Might may not be right, but it is always might. The guy who stood down the row of tanks in Tienneman square undoubtedly has learned that, but who was right?

Sorry Goodcode, no standing ovation from me.

[ August 11, 2005, 09:09 PM: Message edited by: realolman ]

 

[goodcode]

Re: OSHA enforces NFPA70E?

Thank You realolman!
I really cant thank you enough!
Your statements paint an absolutely wonderful picture of the main obstacle to providing safe electrical work practices for all electrical workers.
That main obstacle is "change" followed second by what is essentially a "cowboy" attitude (no offense intended, I run into this everyday.)
No one gets paid enough to expose themselves to serious injury or death when those exposures are easily abated.
I am out there every day just like you realolman. The only difference between you and I is that every time an accident occurs I get the call, not you. Arc Flash injuries and fatalities dont make the newspapers. Electrical workers in general only hear of these incidents when they occur very close to home.
You hit the nail on the head realolman, this is about regulation, it is about following the rules.
I will bet $1,000.00 against $1.00 that when you and all electrical workers are on an aircraft flying to a vacation destination and the stewardess tells you to raise your tray, put your seat in the fully upright position and buckle up, you comply immediately without an argument. Next time tell the stewardess that you think those regulations are bunk and tell her you riding shotgun.
95% of the victims of serious arcflash burns are men just like yourself with years of experience, who take serious pride in what they do, and in reading your post I get the strong feeling that you take great pride in your work.
One common denominator among these burn victims is that they never felt an accident would happen to them. "I know what Im doing," "the other guy just screwed up", "that will never happen to me."
Famous last words.
Accidents happen to even the most qualifed experienced wireman. Thats why we call them accidents. All accidents are preventable if one is interested in prevention.
Thanks again for your post, I mean it sincerely, these issues must be discussed and an open forum is the best.
In closing realolman please reconsider your position on electrical safe work practices, if not for yourself then for loved ones and young electrical workers you bring up in this industry.

 

[69boss302]

Re: OSHA enforces NFPA70E?

realolman:

I would like to give you an ovation. I have been in the same shoes as you. Never caused an arc flash, have seen some but the people that I have been with when they happened were intelligent enough to of taken proper precautions. The regulations get out of hand. It's also becomes an excuse to abuse the supervisor/management. It is used to blame the management. The old story that if there was an accident it was preventable. Who is responsible for what. Is the company responsible to provide safety equipment? or are they responsible for forcing someone to use it? Why does the company have to be blamed if they provided training and safety equipment just because some one failed to use it and got hurt. I must admit that is what I have seen more often than anything.

Someone gets hurt and it's immediately the companies fault. No I am not a company man as you might say. And I know this goes against everything that OSHA and safety people put out, but accidents happen. If they didn't there would be no need to deal with them, and if the world were perfect none of us would have a job. Regulatory stuff though may have been initially OK for one instance always gets blown out of proportion and becomes nothing but a money making generator.

I have been witness more often to were if someone is wearing safety gear they get a superman syndrome and think they won't get hurt, and take more risks. And I have seen where they got hurt, but did anyone get sued because the safety gear didn't protect that person. No that was when it finally came down to "Oh the worker was not properly trained obviously". Training in a class room or even a little OJT does not make some one qualified to perform tasks. I had these arguments many times in the Navy. Theres a difference between qualified, certified and competent. I don't even trust people that are qualified or especially certified. And competence takes time for me to witness a persons ability.

On the management side, I have seen to many managers push people to get the work done, take short cuts and bypass safeties, all in the name of production. But when someone get's hurt the one that made that decision isn't the one that pay's even financially. They always find a way to twist everything around.

Now all that said I do believe in safety, I like the idea of the flame resistant clothing but I hate the moon suits. I don't think any company should have a moon suit, except for POCO's and companies that do that kind of work. A general maintenance oriented person should never have to wear a moon suit.

Well I'll get off my soap box now. This issue can be discussed for a long time on here and many other forums, but the dictations will be made by the insurance companies and governmental controllers that are in place. There is no way around it. I was going to change it to decisions but I think dictations is more appropriate.

If all these safety things really worked, there would be absolutely no accidents.

My tray table and seat back are in the full upright and locked position.

 

[iwire]

Re: OSHA enforces NFPA70E?

realolman, 69boss302 I have read your post and have to ask a question.

Do you think that anyone of the people that have been burned, shocked or killed out right thought it was going to happen to them?

 

[69boss302]

Re: OSHA enforces NFPA70E?

Bob, no I do not think that they thought it was going to happen to them.

I have been on that side for many years, I was an instructor at a Navy Nuclear Power Prototype and one of my biggest questions when I sat on a qualification board pertained to safety. I kicked people out of the board if they violated safety precautions. I have physically removed trainee's from hazardous situations because they did not know what they were doing.

Accidents happen, again if they didn't we wouldn't need to be having these discussions. I hate that the regulations come out so that someone can be blamed for it. That's all they seem to do. They don't really protect anybody. The procedures and safety equipment is there for someone that know's what they are doing to utilize.

I have personally been involved in a manufacturing death, though not through an electrical burn, where OSHA came in and did a thorough investigation, and we the company were found to have no blame in the death. But that wasn't what they could even say. They had to word it that we were operating in accordance with all manufacturers procedures and properly maintaining the equipment. And this is the thing's that never come out, they had to say it that way, just in case a court still decided the other way, they could not even mention there was a death or they could be held liable also.

Our country has become a litigational nightmare where you can't even get up in the morning without being sued. People sue you, especially companies just so you'll pay not to go to court.

Pardon my cynicism, I am going through another non work suit, where there is no grounds for it, but all they want is just enough to make it so it cost's me less to do it this way, than to fight it in court. I say that because no matter what, if you get sued, if costs you.

I have been in the electrical field all my life, I know that people don't expect to have an accident. I see them everyday say what you have said when I told them, put on your gloves, don't work in that panel hot. They always say, I know what I'm doing I won't get hurt. I also believe that if some one does know what he is doing, he is safer working on the equipment than somebody that doesn't know what he is doing and just wears safety equipment.

I am now with the second company where I have mentioned NFPA 70E, and got looked at by upper management with a shoulder shrug. It cost's to follow these regulations. It cost's not to follow the regulations. Who makes the decision to follow them? I am not in the position to enforce things that my company does not follow. Now comes your comment about that is why OSHA fines companies. It all becomes a viscous circle and what it all comes down to is I and people like realolman will be out here making things work, getting beat up and not paid, while a bunch of suit and ties sit in an office and say that we can't do our job's.

 

[iwire]

Re: OSHA enforces NFPA70E?

Boss 302 Well now I am just confused on your position.

You say are for safety but seem to be against PPE.

I do agree in that individuals should be held more accountable for their own actions however that brings up some conflicts.

If the companies are not held responsible for forcing the use of PPE certainly some companies would pressure the workers to skip the safety procedures to get more production.

When an accident happens the company could simply say

"We provided the PPE and told them to use it. The employee is at fault for not following the rules"


There are no easy answers I am certainly guilty of breaking OSHA rules but I have been making serious strides in changing my habits.

No amount of money is worth me missing my kids growing up.

No amount of production is worth me missing my retirement.

Bob

[ August 12, 2005, 09:24 AM: Message edited by: iwire ]

 

[petersonra]

Re: OSHA enforces NFPA70E?

I think the bottom line is that we need to come up with ways to rationally deal with the risks inherent in the use of electricity.

The problem has been that there are a lot of safety charlatans who have never actually done anything useful making a lot of the rules up that are of dubious benefit.

My experience with a lot of these guys makes me think they would not be able to ever find a real job, so they get stuck in the safety department because the company thinks that they need a safety "expert".

I think the tide is turning though, towards more rational safety practices, that actually do improve safety without going overboard. I do not want to work in an unsafe environment anymore than I want to breath polluted air.

I am not fully convinced that there is a need to put on a moonsuit to use a VOM inside a PLC cabinet, yet that seems to be the suggestion being made by some. This kind of thing is nuts, and if it takes hold, it will just plain shutdown the US economy.

There has to be a better way. I am not sure what that way is but I have to believe that the millions of times that this type of operation has been performed safely means that it can be done safely, and w/o a moonsuit.

One possibility is to section off control panels so that the controls (mostly low voltage) is seperate from the 480V, so that you can check the control side out without the need to get near the stuff that might bite you.

Better diagnostics on motor starters and other devices could eliminate the need for some of this type of work, but the massive cost of retrofitting existing equipment makes retrofits unlikely.

If it starts to cost $500 every time you go to check whether a fuse is blown or not, you might as well just send all the work over to China tomorrow and close down the country.

 

[iwire]

Re: OSHA enforces NFPA70E?

Originally posted by petersonra:
One possibility is to section off control panels so that the controls (mostly low voltage) is seperate from the 480V, so that you can check the control side out without the need to get near the stuff that might bite you.

Bob I agree entirely and the costs of using PPE will IMO bring out better designs in equipment such as you describe.

Necessity is the mother of invention, or so I am told.

 

[69boss302]

Re: OSHA enforces NFPA70E?

Yes Bob, I agree with what Bob said

Anyway, my stand is I am not against PPE, I am not against safety. I am against that I have to force someone to wear safety equipment when it may actually make it less safe. And the way the regulators or I should say the way the companies get forced to adhere is they have to hire and praise somebody that follows or knows the safety aspects without knowing anything about electricity.

Also you get the people that will bypass the safety reg's and go, see no one got hurt so it's all nonsense. These are the one's that make it real bad. Because a company will begin to deal with contractors that will bypass safety aspects because now the company can blame the contractor. Again, nothing but a vicious circle. But no wait, we'll make the company responsible for contractors as well.

OSHA themselves will admit that they don't even look into things unless there is a certain amount of accidents or injuries.

And why do they send everything to China, not just because of lower wages. They don't have to contend with all the regs. China is a giant people well. If somebody gets hurt they just put in somebody else and probably pay them even less. There is always somebody willing to do the job, just because it's a job.

 

[iwire]

Re: OSHA enforces NFPA70E?

Originally posted by 69boss302:
And why do they send everything to China, not just because of lower wages. They don't have to contend with all the regs. China is a giant people well. If somebody gets hurt they just put in somebody else and probably pay them even less. There is always somebody willing to do the job, just because it's a job.

Now I am even more confused.

Would you want the US to be like countries that treat workers as just another replaceable tool?

Admittedly my knowledge of arc fault calculations is lacking but the suggestion that only power company workers need moon suits strikes me as wrong.

The incident energy at large 480 volt switch gear can certainly be enough to take you out without it being from a shock.

What would be your ideal answer?

Bob

 

[petersonra]

Re: OSHA enforces NFPA70E?

The problem is that if taken to its logical extreme (which is what will happen eventually), someone will have to do an arc flash calculation on every outlet in the building and put a sticker on it saying what level of PPE is required to plug in your coffee maker.

We need to kill off this kind of thing before it gets that far, while acknowledging that there are some hazards that need to be dealt with.

At some point, we may have to accept that idea of some kind of risk/benefits analysis. Is saving a single person's life worth $1 billion? Is it worth doing if it costs 100,000 people their jobs? these are questions that need to be addressed and as a country we are pretending they don't even exist.

 

[iwire]

Re: OSHA enforces NFPA70E?

Originally posted by petersonra:
The problem is that if taken to its logical extreme (which is what will happen eventually), someone will have to do an arc flash calculation on every outlet in the building and put a sticker on it saying what level of PPE is required to plug in your coffee maker.

I would not call that logical although I agree that unfortunately it could go there.

I think the only way to change OSHA is an act of congress, I do not see that happening anytime soon.

 

[69boss302]

Re: OSHA enforces NFPA70E?

Well Bob perhaps I was not as clear as I should be. I don't think any job that requires a moon suit should be done by a general maintenance electrician type person. If it requires a moon suit it should be done by a competent company experienced in that work. Better yet I had a commanding officer that put it even better.

I had some work to do on a switchgear that powered the galley. I had scheduled the work and informed the Chief in charge of the galley. He went off full force to see the CO and said that it would ruin all his schedule and he would not be able to prepare either the afternoon or evening meal. The CO listened to him rant and rave, I told the CO, that the job could be done without turning off the switchgear, we would just have to do extra safety procedures to remove the breaker we had to work on. The CO then asked me one question. "Can it be done safer with it turned off?" I said of course. Without even a breath in between he looked at the Chief in charge of the galley and said "Break out he lunch meat Chief". Put his head back into his paper work and told me to fix the switchgear.

The unfortunate thing is manufacturing companies never look at that. There are many other things you could blame for it, but it is always production driven. Unwillingness to cooperate and reschedule just a little. It has been done for years where they did not have to turn it off, now it is "unacceptable" to turn something off just to try and make it safe to work on and then turn it back on. Production can not be stopped for anything. And instead of trying to get the fact through that it probably even cost less to turn it off for just a little bit to either remove a breaker or do something to make it safer, it becomes an exercise in extreme safety precautions which really do not guarantee that nobody will be hurt.